Pennington Hennessy — Lifework Career Analysis

Data Security & Privacy Policy

Last updated: April 2026

Lifework is a structured career analysis programme that asks you to reflect on your life history, values, personality, and professional aspirations. We recognise that the information you share is personal, sensitive, and deserving of the highest standard of care. This document explains, in plain terms, how your data is stored, who can access it, what happens when it is processed by artificial intelligence, and what rights you hold over it.

We are committed not only to taking data security seriously, but to being transparent about every layer of the system so that you can make an informed decision about participating.


1.What data we collect

Lifework collects the following categories of information during the programme:

Identity and contactName, email address, login credentials
Life history narrativeCareer timeline, formative experiences, background interview responses
Psychometric responsesVIA Character Strengths survey answers, IPIP personality inventory responses
AI-generated analysisCareer themes, strengths summaries, and coaching insights generated from your inputs
Technical usage dataLogin timestamps, browser type, IP address (used for security purposes only)

We do not collect payment card data, health records, or any information beyond what is directly relevant to the career analysis programme.


2.How your data is stored

Your data is stored in a managed cloud database provided by Manus (operated by Butterfly Effect Pte. Ltd., headquartered in Singapore). Manus is the platform on which Lifework is built and hosted.

Encryption. All data is transmitted over HTTPS (TLS 1.2 or higher), meaning it is encrypted in transit between your browser and our servers. Data at rest in the database is encrypted using industry-standard AES-256 encryption.
Access controls. Your data is accessible only to you (via your authenticated account) and to Pennington Hennessy as the programme operator. No other party has routine access to your individual responses.
Data residency. Manus infrastructure may operate across multiple regions, including Singapore and the United States. Manus has appointed a Data Protection Officer and EU/UK GDPR representatives (EDPO, Brussels and London) to handle cross-border data transfer obligations.

3.How the AI component works — and what Anthropic does with your data

Lifework uses AI (specifically, Anthropic's Claude model) to analyse your survey responses and generate personalised career insights. This is the part of the system that clients most often ask about, and the answer is unambiguous.

Anthropic does not train its AI on your data

Anthropic's Commercial Terms of Service state explicitly:

"Anthropic may not train models on Customer Content from Services."

This is a contractual commitment, not merely a policy preference. Because Lifework accesses Claude through the Anthropic commercial API, your inputs and the AI's outputs are classified as Customer Content — and Anthropic is contractually prohibited from using that content to train or improve its models.

This is distinct from Anthropic's consumer products (Claude.ai Free, Pro, and Max plans), where users may choose whether to allow their conversations to be used for training. The commercial API — which is what Lifework uses — carries an unconditional no-training commitment regardless of any user preference settings.

What Anthropic does do with your data

When your responses are sent to the Anthropic API for analysis, Anthropic processes them as a data processor acting on Pennington Hennessy's behalf. In this role, Anthropic processes your inputs to generate AI responses and then discards the session data. It may retain data temporarily for security monitoring, abuse detection, and legal compliance, but does not combine your data with other users' data for any commercial purpose, and does not sell or share your data with third parties for advertising or marketing.

How the AI analysis is used

The AI-generated insights produced from your survey responses are stored in the Lifework database and are visible to you and to your Pennington Hennessy coach. They are used solely for the purpose of the career analysis programme and are not shared with any third party, including prospective employers, without your explicit consent.


4.Manus platform security

Technical safeguards. Manus employs technical, organisational, and physical safeguards designed to protect personal information. These include encrypted data transmission, access-controlled infrastructure, and regular security procedures.
GDPR compliance. Manus has appointed a Data Protection Officer and has designated EDPO as its EU and UK GDPR representative. For users in the United Kingdom and European Economic Area, Manus processes personal data in accordance with the UK GDPR and EU GDPR respectively, relying on contractual necessity and legitimate interests as its legal bases.
Data subject rights. You may contact Manus directly at [email protected] to exercise your rights of access, correction, deletion, or portability in respect of data held on the platform.

5.Your rights

As a Lifework participant, you hold the following rights over your personal data:

AccessYou may request a copy of all personal data we hold about you
CorrectionYou may ask us to correct any inaccurate information
DeletionYou may request that your account and all associated data be deleted
PortabilityYou may request your data in a machine-readable format
ObjectionYou may object to any processing you believe is not justified
Withdrawal of consentYou may withdraw from the programme at any time

To exercise any of these rights, contact Pennington Hennessy directly at the email address provided in your programme welcome communication. We will respond within 30 days.

If you are located in the United Kingdom, you also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.


6.Data retention

We retain your Lifework data for the duration of your engagement with Pennington Hennessy and for a period of two years thereafter, to allow for follow-up coaching conversations and longitudinal career reflection. At the end of this period, or upon your written request, all personal data will be permanently deleted from the database.

AI session data processed by Anthropic is not retained by Anthropic beyond the immediate processing session (except where required for security or legal compliance, as described above).


7.What we do not do

To be explicit about the boundaries of our data use:

  • We do not sell your data to any third party.
  • We do not share your data with prospective employers or recruitment firms without your explicit written consent.
  • We do not use your data for advertising or marketing purposes.
  • We do not allow Anthropic or Manus to use your data to train AI models.
  • We do not store your data outside of the Manus platform infrastructure described in this document.

8.Questions and contact

If you have any questions about this policy, or wish to exercise your data rights, please contact:

Pennington Hennessy

Email: [email protected]

Website: penningtonhennessy.com

Manus (Butterfly Effect Pte. Ltd.) — platform enquiries

Email: [email protected]

Anthropic — AI processing enquiries

Email: [email protected]


References

  1. Manus Privacy Policy (Butterfly Effect Pte. Ltd.) — manus.im/privacy
  2. Anthropic Commercial Terms of Service (effective June 17, 2025) — anthropic.com/legal/commercial-terms
  3. Anthropic Privacy Center — "Is my data used for model training?" — privacy.claude.com